Document e0Kr2GOrV5LqZOV7JM0aKzXy

HEALTH AIID EHVI3.0'J:1EWTAL AFFAIRS CTHITTEE Membership Assistance .. At the last annual membership meeting, the Board asked what the Institute or the Health and Environmental Affairs Committee could do to assist members who were having problems with safety, health or environmental regulations. _ Specifically, the Board asked the Committee: ' 1. What the manufacturer can do himself to insure compliance with regulations? 2. What outside help is available in order to assure compliance? 3. A summary listing of citations alleged against members by regulatory agencies and the steps that industry took to ' ' object or move into compliance.. - ! '. The Committee has met and addressed these issues. It is felt the Committee and the Institute's role was that of a consultant. It would: ,. 1. Motify members when new regulations are proposed or adopted. 2. Advise on experts in the field who could help members. 3. l,ork with regulatory agencies in an effort to represent the interest of the members. 4. Provide advice when requested, related to specific member ' interests, '' It was concluded that each manufacturer must establish a person br persons 1 who must develop familiarity with the regulations and take action for compliance within their own organization. i What outside help is available . i In order to assist the FMSI members in finding experts and information a listing of publications and services in the occupational safety, health ' and environmental areas was developed and distributed to the membership on February 19, 1981. ' In addition, a listing of firms and Individuals to consult in industrial hygiene, asbestos sampling and laboratory analysis was compiled and ! distributed. . j On April 30, 1981 a summary of the background and expertise of the Committee t members was distributed to the membership along with a summary of the various projects completed. This information was developed in order to : inform the membership of the consulting capability within the group and | projects that have been done on behalf of the members. FMSI-0361 FMSI 02795 T Other actions to assist Members During 1981, a series bf informational bulletins were developed and distributed to the members. Without going into specifics, the sub jects covered were: material safety data sheets, a summary of the current EPA requirements regulating hazardous waste disposal,-and a guidance document Indicating that asbestos had been specifically eliminated from hazardous wastes defined by EPA under PvCRA. Exchange of information - Citations and Corrective Action Some of the Committee members expressed concern that their management representatives would not approve the release of information to PMSI in that .some methods of corrective action were considered proprietary information. Further, Legal Counsel advised there could be some ' question as to whether members who are under citation would want other companies to know Information relating to this legal activity. It waB decided that a questionnaire would be developed and circulated amongst the membership to determine how much interest and willingness there was to provide the type of information requested by the Board of Directors. That questionnaire was transmitted by Bulletin <*715 on April 30, 1981. While there appears to be interest in the exchange of Information, it does not appear to be practical with the limitations that would be required to protect the information considered propri etary. . EPA . . . ... .. , .. . .. . ' On January 26, 1981 the EPA's office of Toxic Substances proposed requirements for the reporting of asbestos usage in the United .States. A brake lining or clutch facing manufacture would be classified as a primary processor as raw asbestos is used in the friction product. A ' rebuilder would be considered a secondary processor. Thus, both categories would become subject to the reporting requirements. The Health and Environemnetal Affairs Committee generated PMSI Bulletin //708 on February 18, 1981 advising the membership of the proposed re quirements and solicited comments in order to respond to the EPA on the impact to PISI members. On March 19, 1981 a response to tbe EPA was submitted to the Board of Directors for review and approval. The document was then transmitted to EPA on March 25, 1981. .' - Our committee would like to point out to the Board and the members the following information regarding this proposed rule. . There has not beem any further action on this EPA proposal which would indicate it t#ill be adopted. There is a strong need for information within EPA - specifically related to asbestos usage within the friction materials business. As a result, we suspect this proposal will be re-activated. mS\ 02796 . Should the proposal be adopted in its present form, members of the FHSI will find an additional administrative burden Imposed. A couple of examples will explain this point. . Each member would be requested to generate data covering a 10-year period from 1971 through 1980. Specifically, the EPA would want to know the quantity of asbestos used by each company by type and grade. . A recordkeeping requirement to prepare a customer list containing the name, address, technical contact, phone number and amount of asbestos sent to each customer. . A request for the development of a listing of all pollution control equipment along with dates of in stallation and first use by month and year. . Me will continue to monitor the developments of this proposal. -lew Administration (SPA) . Under the Reagan Administration, there has developed a 'new spirit of cooperation" in the EPA. Through the efforts of the Asbestos Information Association, the membership of MSI is now represented at a series of informal off-the-record meetings between industry and SPA ruleraakers. The EPA Office of Toxic Substances (TOSCA) has been reviewing the need for regulation of asbestos in the friction materials section. ..* Currently representing industry interests in these meetings are Bob Plgg, AIA; John Karsh, Raybestos-Manhattan; Bill Krebs, General llotors and myself, representing FIISI. Being discussed are such issues as: . An industry questionnaire to determine the quantity of asbestoscontaining drum brake usage both in current demand and projected estimates for the future. . An industry labeling requirement. . . A general review of EPA training and information materials re lated to friction material products. Hew Administration (OSHA) There is a temporary hold on all OSKA regulatory activity. There is in dication that the new administration wants to move from a compliance enforcement agency to that of a consulting educational role. It is still to early to determine which direction will be taken. Respectfully submitted. J. VI. Armstrong FMSI 02797